A final compliance report confirms significant progress, but several key reforms remain unfinished months after lawmakers and citizens expected them to be done.
South Carolina legislators gave state agencies a firm deadline: March 7, 2026. By that date, every recommendation that did not require a change in law from a sweeping forensic accounting review of the state’s finances was supposed to be fully implemented. The SC Public Interest Foundation had been tracking that deadline closely, and in a February 2026 article laid out the stakes clearly. Now, with a final compliance report from Forvis Mazars dated March 9, 2026, there is an official accounting of where things stand. The picture is better than a worst-case scenario but far short of the finish line the law required.
To understand why this matters, some background is necessary. Starting in 2012, a mapping error inside the state’s accounting software, combined with poor internal quality controls withing the Comptroller’s Office, quietly excluded or double-counted certain cash and appropriations transfers within the Annual Comprehensive Financial Report, overstating the General Fund’s equity by $5.9 billion over nearly a decade. That error, compounded by two others, produced a cumulative $3.53 billion misstatement that went undetected until sometime in 2021-2022 it became impossible to ignore. Citizens had every reason to lose faith in the people pf the government managing their money.
In response, the General Assembly in April 2024 hired AlixPartners, an internationally recognized forensic accounting firm, to dig into the state’s financial reporting practices. Their report, released January 15, 2025, identified 25 recommendations spread across the Comptroller General’s Office (CGO), the State Treasurer’s Office (STO), and the Office of the State Auditor (OSA). The General Assembly then passed Senate Bill S.253 in 2025, which required an independent compliance consultant (ICC) to oversee implementation and mandated that all recommendations not requiring statutory change be completed by March 7, 2026. Forvis Mazars was hired for that oversight role, and their final report was delivered just two days after the deadline.
What We Got Right in Our February Article
Our February 2026 piece offered a summary of where things stood with roughly three weeks left before the deadline. At that point, only three recommendations were fully complete: AP-17 (the correction of the $1.8 billion SCEIS cash balance), AP-18 (the clarification of Note 15 in the FY 2022 ACFR), and AP-19 (the evaluation of the accuracy of the FY 2022 statistical tables). Nine more were marked “Complete, Pending Compliance Review,” meaning the work had been done but awaited final verification. Ten others were still ongoing.
We paid particular attention to recommendations AP-20 through AP-23, all of which targeted the CGO’s handling of topside accounting entries and budget processes. Those were the practices that allowed the original errors to go unnoticed for so long, and our Foundation flagged them appropriately as high stakes. On AP-21, which required an assessment of all prior topside entries related to negative cash offsets, our article noted it had not even started as of December 2025 and had only been initiated in January 2026. That was a legitimate concern, and the final report does not entirely resolve it. With all these points raised in our prior article in mind we will now turn to the final report.
What the Final Report Shows
Forvis Mazars consolidated the 25 AlixPartners recommendations with additional recommendations from a separate Mauldin and Jenkins report on the ACFR development process, arriving at 32 total. Of those, the report marks 14 as Complete, 12 as Complete Pending Compliance Review, 3 as In Progress, and 3 as Not Within Scope.
The three recommendations still In Progress are AP-5, AP-22, and AP-23. AP-5 covers the CGO’s cash and investments reconciliation policies and procedures; those were still being developed as of March 9, with completion now expected in April 2026 and compliance review pushed to November 2026 at the earliest. AP-22, which requires eliminating workarounds in SAP and reevaluating STO staff permissions in the accounting system, was undergoing user acceptance testing at the time of the report. AP-23, the evaluation of the broader SCEIS configuration, is the longest runway of all, with a completion date now projected for December 2027 tied to the state’s planned upgrade to the S/4 HANA system.
That last item, AP-23, is worth dwelling on. The state has been aware since at least early 2025 that its SAP enterprise system configuration needed review. The recommendation came directly from the AlixPartners forensic investigation. Pushing the final resolution to December 2027 because of a separate software upgrade is a reasonable explanation, but it is also a reminder that some of the structural changes necessary to prevent another decade-long accounting error are still years away from completion.
The State Treasurer’s Office
The February article noted that the State Treasurer’s Office had completed its recommendations, specifically citing AP-4, which required the STO to develop comprehensive policies for reporting cash and investments. The final report confirms that AP-4 is marked Complete, and rightly so. Forvis Mazars reviewed the STO’s reconciliation procedures and found them consistent with the policy. That is meaningful, substantive progress, the result of real institutional effort.
The STO’s broader role in the compliance picture reflects an office that has done its part while navigating challenges that originated elsewhere. AP-7 required the CGO to train the STO on how cash and investments appear in the ACFR and how negative cash can occur. Forvis Mazars marks it Complete, pointing to three narratives the CGO provided over the course of the engagement, including a calculation template delivered in January 2026. The STO engaged with that process throughout. But it is worth noting that as recently as January 30, 2026, the STO stated in its own monthly status report that it had not received enough information from the CGO to independently recalculate General Fund cash and cash equivalents for FY 2024 or FY 2025. That candid assessment reflects an office being transparent about the limits of what it had been given, not an office that failed to try.
Forvis Mazars concludes that the third narrative included a calculation template sufficient for a reasonable estimate. The STO is not disputing that in bad faith; it is an office that takes precision seriously and was appropriately cautious about the difference between an estimate and verified figures. When the office responsible for the state’s cash raises a concern about data adequacy, that concern deserves to be heard as a sign of rigor, not treated as an obstacle. The STO’s transparency here reflects exactly the kind of institutional honesty a compliance process should encourage.
The 2024 Mauldin-Jenkins (MJ) report also contained recommendations that were subject to the General Assembly’s directive to implement forensic accounting corrective recommendations. From that report, items MJ-9(a) and MJ-9(b), both related to the Treasurer’s responsibility to produce reports the CGO needs for ACFR compilation, are listed by Forvis Mazars as Complete, and the STO earned that designation. Working alongside the CGO, the STO developed new SCEIS reports by September 2025 to automate part of the process. Forvis Mazars tested those reports in October 2025 and found they drew from common data. The STO delivered on its obligations, modernized a reporting workflow, and helped move the state toward a more reliable system. That is a genuine contribution to resolving an accounting problem that long predated this compliance effort and was not of the STO’s making.
The CGO’s Unfinished Work
The CGO carries the heaviest load in this reform effort, and the Forvis Mazars report reflects that. The office worked with an accounting consultant firm called Eide Bailly throughout 2025 to develop a wide range of new policies covering everything from workpaper standards to journal entry protocols to agency adjustment notices. Most of these are now in the hands of CGO staff, and training was scheduled for mid-March 2026, just after the deadline. That timeline alone illustrates why the “Complete, Pending Compliance Review” label requires scrutiny. Additionally, what this means is that the most recent ACFR was not generated utilizing the corrected or improved policies, but instead prepared under a somewhat improvised or “ad-hoc” policy that does not to appear to have ever been formally reviewed and approved by neutral, outside experts. The policies finalized in late 2025 and training delivered in March 2026 will be tested for the first time in the FY 2026 ACFR cycle. The actual compliance review cannot happen until after the June 30, 2026 ACFR is issued, likely in early 2027.
The February article specifically flagged AP-21 as a worry, noting it had barely gotten started in January 2026. The final report marks it Complete, and notes that CGO and Eide Bailly reviewed topside adjustments from FY 2022 through FY 2024 and concluded that the negative cash handling in those years would not have materially differed had the new policy been in effect. That is a meaningful finding. However, AP 21 does not confine itself only to FY2022-2024; its states that “all” topside accounting entries must be assessed – which would appear to mean (or strongly imply) that it should at least go back to the “anchor year” identified by AlixPartners, which is FY2015. Additionally, the Forvis report was produced and finalized right up against the deadline, and it relies entirely on work performed by CGO’s own staff and the consultant they hired. There was no independent verification by Forvis Mazars of the underlying transactions.
AP-22, the elimination of SAP workflow workarounds and the reevaluation of STO staff permissions, remained in user acceptance testing as of the report date. Implementation was planned for March 19, 2026, twelve days after the statutory deadline. That is not a catastrophic miss, but it is a miss. The February article said it was on track. It was close, but not there.
The Bigger Picture
Forvis Mazars conducted 203 meetings over the course of the engagement, made roughly 84 documentation requests, and reviewed hundreds of documents. That is a substantial investment. And real work happened because of it. The $1.8 billion SCEIS correction was made under observation by AlixPartners. New policies on journal entries, workpapers, error tracking, and agency communications were written, reviewed, and finalized. A joint audit arrangement between the OSA and Mauldin and Jenkins was restructured. The CGO hired a Quality Assurance Manager. New SCEIS reports were built and tested. These are not small things.
But our February article asked a direct question about whether the March 7 deadline would be met, and the honest answer based on the final report is: not entirely. Three recommendations remain In Progress. The compliance reviews for twelve more cannot happen until after the FY 2026 ACFR is issued. And at least one reform, the SCEIS configuration review, now has a completion horizon of December 2027.
The final report was placed on the General Assembly’s Joint Bond Review Committee agenda for its recent meeting on March 25th, not for any formal action, but only to be “received as information.” There was no discussion of the contents of the report by the Committee, nor was anyone from Forvis Mazars or any of the state agencies involved in the matter called before the Committee to testify or respond to questions. The only comment made by the Committee was from its Chairman, Sen. Harvey Peeler, who in essence only stated that the report was of importance and should be carefully reviewed and understood by its members – despite the fact that the report had been issued by Forvis approximately two weeks prior. Oddly, there was no request for an extension of time for the completion of the incomplete items, which S.253 stated could be granted by the JBRC if found warranted. It remains unclear if Forvis is going to continue working for the State to ensure that the outstanding incomplete items are carried to completion.
Our Foundation was right to watch this closely and right to push for accountability. The state’s financial accounting management weakened not because of one rogue actor but because of institutional failures, predominately at the CG’s office, that persisted for years without serious challenge. The policies now being written and the new systems now being built are necessary. Whether they are sufficient depends on whether the people running these offices treat them as genuine operating frameworks to be adhered to, or as documents simply produced to satisfy an oversight requirement and end the public scrutiny. That question will not be answered by a compliance report. It will be answered by the FY 2026 ACFR.
Go to the Bottom of the Page for a Table with the Final Statuses of the Recommendations
The table below summarizes the final status of all 32 consolidated recommendations as reported by Forvis Mazars on March 9, 2026. Rows highlighted in yellow indicate recommendations that were not completed by the March 7, 2026 deadline and still require action. Note that all highlighted items are the responsibility of the CGO and/or SCEIS, the State Treasurer’s Office completed all of its assigned recommendations.
